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Compliance
Message from the President and CEO. It is important to A. T. CROSS Company’s continued success that its policies concerning business ethics be clearly communicated throughout the corporation. CROSS, as a major international manufacturer and distributor of innovative writing instruments, timepieces, business accessories, and sunglasses under the Costa Del Mar and Native Eyewear brand names, has established a reputation for fair and ethical business practices. CROSS values this reputation and will make every effort to maintain these high business ethics standards. The message is simple and direct: in the conduct of A. T. CROSS business, observance of the law and adherence to ethical business conduct are requirements, without exception.

Reporting Violations. It is a priority of the Company that it, and its employees, act ethically and legally. In addition to fostering an atmosphere that the Company will not accept, illegal acts or improper conduct may also subject CROSS to severe civil and criminal penalties. It is therefore very important that any illegal activity or violations of the Company’s Code of Ethics and Business Conduct (“Code”) be promptly brought to the Company’s attention. This would include, but not be limited to, questions or complaints regarding the Company's accounting, internal accounting controls, or auditing matters.

Any CROSS employee who believes or becomes aware that any violation of this Code has occurred or that any illegal or questionable activity has been engaged in by a CROSS employee or by non-employees acting on CROSS’s behalf, must promptly report the violation or illegal activity in person, by phone or in writing, to one of the following persons:

Contact Phone/Email
Email (may be anonymous) compliance@cross.com
Phone – Compliance Hotline (may be anonymous) (401)335-8326
Staff Contacts  
Vice President, Legal and Human Resources (401) 335- 8538; or by email to compliance@cross.com
Senior Vice President and Chief Financial Officer (401) 335- 8470
Audit Committee Chair By email to audit-chair@cross.com
Senior Manager, Internal Audit (401) 335- 8307
Employee’s immediate supervisor, department head or another senior manager  

In situations involving high level employees, the Chief Executive Officer or the Chair of the Audit Committee of the Board of Directors may be contacted directly, as appropriate, via email to audit-chair@cross.com. Additionally, anyone wishing to contact the Chair of the Audit Committee may also send correspondence by mail to the attention of the Vice President, Legal and Human Resources at One Albion Road, Lincoln, RI 02865. The Vice President, Legal and Human Resources will forward such mail unopened (unless there is a perceived security risk) to the Chair of the Audit Committee.

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